On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing gaps in the existing anti-money laundering and countering of the financing of terrorism (AML/CFT) framework as it applies to digital assets. … Continue Reading
Andrew N. D'Aversa
daversaa@ballardspahr.com | 215.864.8113 | view full bio
Andrew focuses his practice in matters involving white collar defense/internal investigations and complex civil litigation. His work includes cases involving allegations of money laundering and fraud schemes committed through financial institutions. His work in the BSA/AML sphere also extends to advising clients on state money services statutes and regulations relating to virtual currency and related products. Andrew has served as a judicial law clerk to the Honorable Noah L. Hillman of the U.S. District Court for the District of New jersey, and to the Honorable Anthony J. Sirica for the U.S. Court of Appeals of the Third Circuit.
Connecticut Department of Banking issues consumer and industry advisory on money transmission
By Andrew N. D'Aversa & John D. Socknat on
Posted in Money Transmission, State Licensing
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. First, the Department notes the “significant disruption to traditional money transmission systems” caused by the “increased use of technology to enable immediate payment mechanisms” and “the explosion of virtual currency.” … Continue Reading
OCC highlights risks associated with compliance staffing concerns, Russia sanctions, environmental crimes, cyber attacks and digital assets
By Andrew N. D'Aversa on
On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under its regulatory umbrella, focusing on Russia sanctions, climate-related risk, and rising inflation. Despite these challenges, the OCC believes that “[b]anks’ financial condition remains strong and positioned to deal with the economic headwinds.”… Continue Reading